RMP Program 3

40 CFR 68.65 - The employer must complete a compilation of written process safety information before conducting any process hazard analysis required by the rule. The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving regulated substances. This process safety information must include information pertaining to the hazards of the regulated substances used or produced by the process, information pertaining to the technology of the process and information pertaining to the equipment in the process.

Information pertaining to the hazards of the regulated substances in the process must consist of the following:

1. Toxicity information;
2. Permissible exposure limits;
3. Physical data;
4. Reactivity data;
5. Corrosivity data;
6. Thermal and chemical stability data; and
7. Hazardous effects of inadvertent mixing of different materials.

Information concerning the technology of the process must include the following:

1. A block flow diagram or simplified process flow diagram;
2. Process chemistry;
3. Maximum intended inventory;
4. Safe upper and lower limits for such items as temperatures, pressures, flows or compositions; and,
5. An evaluation of the consequences of deviations.

Information pertaining to the equipment in the process must include:

1. Materials of construction;
2. Piping and instrument diagrams (P&ID's);
3. Electrical classification;
4. Relief system design and design basis;
5. Ventilation system design;
6. Design codes and standards employed;
7. Material and energy balances; and
8. Safety systems.

The employer must document that equipment complies with recognized and generally accepted good engineering practices. For existing equipment designed and constructed in accordance with codes, standards or practices that are no longer in general use, the employer must determine and document that the equipment is designed, maintained, inspected, tested and operating in a safe manner.

40 CFR 68.67 - The employer must perform an initial Process Hazard Analysis (PHA) on processes covered by the rule. The process hazard analysis must be appropriate to the complexity of the process and must identify, evaluate and control the hazards involved in the process. The employer must determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process and operating history of the process. The PHA must address:

1. The hazards of the process;
2. The identification of any previous incident which had a likely potential for catastrophic consequences;
3. Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases;
4. Consequences of failure of engineering and administrative controls;
5. Stationary source siting;
6. Human factors; and
7. A qualitative evaluation of a range of the possible safety and health effects of failure of controls.

The process hazard analysis must be performed by a team with expertise in engineering and process operations, and the team must include at least one employee who has experience and knowledge specific to the process being evaluated. Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology being used.

The employer must establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.

At least every five years after the completion of the initial PHA, the PHA must be updated and revalidated. The employer must retain process hazard analyses and updates or revalidations for the life of the process.

40 CFR 68.69 - The employer must develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and must address at least the following elements:

1. Steps for each operating phase;
2. Operating limits;
3. Safety and health considerations; and
4. Safety systems and their functions.

Operating procedures must be readily accessible to employees who work in or maintain a process. They must be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, equipment and changes to stationary sources. The employer must certify annually that these operating procedures are current and accurate.

The employer must develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a stationary source by maintenance, contractor, laboratory or other support personnel. These safe work practices apply to employees and contractor employees.

40 CFR 68.71 - Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, must be trained in an overview of the process and in the operating procedures. The training must include emphasis on the specific safety and health hazards and emergency operations, including shutdown and safe work practices applicable to the employee's job tasks.

Refresher training must be provided at least every three years, and more often if necessary, to each employee involved in operating a process, to assure that the employee understands and adheres to the current operating procedures of the process. The employer must determine the appropriate frequency of refresher training after consulting with the employees involved in operating the process. The employer must be sure that each employee involved in operating a process has received and understood the training. They must prepare a record which contains the identity of the employee, the date of training and the means used to verify that the employee understood the training.

40 CFR 68.73 - The employer must establish and implement written procedures to maintain the on-going integrity of process equipment. Process equipment includes:

1. Pressure vessels and storage tanks;
2. Piping systems;
3. Relief and vent systems and devices;
4. Emergency shutdown systems;
5. Controls; and
6. Pumps.

The employer must train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner.

Inspections and tests must be performed on process equipment. Inspection and testing procedures must follow recognized and generally accepted good engineering practices. The frequency of inspections and tests of process equipment must be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience.

The employer must document each inspection and test that has been performed on process equipment. The documentation must identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed and the results of the inspection or test.

The employer must correct deficiencies in equipment that are outside acceptable limits before further use, or in a safe and timely manner when necessary means are taken to assure safe operation. Appropriate checks and inspections must be performed to assure that equipment is installed properly and consistent with design specifications and the manufacturer's instructions. The employer must assure that maintenance materials, spare parts and equipment are suitable for the process application for which they will be used.

40 CFR 68.75 - The employer must establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, procedures, and changes to stationary sources that affect a covered process. The procedures must address the following prior to any change:

1. The technical basis for the proposed change;
2. Impact of change on safety and health;
3. Modifications to operating procedures;
4. Necessary time period for the change; and,
5. Authorization requirements for the proposed change.

Employees involved in operating a process, and maintenance and contract employees whose job tasks will be affected by a change in the process, must be informed of, and trained in, the change prior to startup of the process or affected part of the process. If a covered change results in a change in the process safety information, such information must be updated accordingly. If a covered change results in a change in the operating procedures or practices, such procedures or practices must be updated accordingly.

40 CFR 68.79 - The employer must certify that they have evaluated compliance at least every three years to verify that procedures and practices are adequate and are being followed. The compliance audit must be conducted by at least one person knowledgeable in the process. A report of the findings of the audit must be developed. The employer must promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected. The two most recent compliance audit reports must be retained on file.

40 CFR 68.81 - The employer must investigate each incident which resulted in, or could reasonably have resulted in, a catastrophic release of a regulated substance as promptly as possible, but not later than 48 hours following the incident. An incident investigation team must be established and consist of at least one person knowledgeable in the process involved, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident. A report must be prepared at the conclusion of the investigation, which includes:

1. Date of incident;
2. Date investigation began;
3. A description of the incident;
4. The factors that contributed to the incident; and,
5. Any recommendations resulting from the investigation.

The employer must establish a system to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions must be documented. The report must be reviewed with all affected personnel whose job tasks are relevant to the incident findings. Incident investigation reports must be retained for five years.

40 CFR 68.150 - The employer must submit a single RMP that includes the required information for all covered processes and revise or update the RMP as follows:

1. At least once every five years from the date of its initial submission or most recent update, whichever is later;
2. No later than three years after a newly regulated substance is first listed by EPA;
3. No later than the date on which a new regulated substance is first present in an already covered process above a threshold quantity;
4. No later than the date on which a regulated substance is first present above a threshold quantity in a new process;
5. Within six months of a change that requires a revised hazard review;
6. Within six months of a change that requires a revised offsite consequence analysis;
7. Within six months of a change that alters the program level that applied to any covered process;
8. Within six months of any accidental release meeting the five-year accident history reporting criteria, or by the time the RMP is next updated, whichever is earlier;
9. Within one month of any change in the emergency contact information required; and
10. Within six months if a stationary source is no longer covered under the rule.